https://www.taxtmi.com/caselaws?id=784250 Disallowance under s.14A r.w. Rule 8D was held unsustainable because the AO failed to record the mandatory satisfaction under s.14A(2) that the assessee's claim of having incurred no expenditure to earn exempt dividend income was incorrect. The Tribunal held that the AO must examine the P&L and books to identify any expenditure relatable to exempt income and record a precise finding before invoking Rule 8D; a generalized assertion without evidentiary support does not meet the statutory threshold. Relying on SC (Maxopp), recording satisfaction was treated as a sine qua non. Consequently, the s.14A disallowance, as affirmed by CIT(A), was deleted and relief granted to the assessee. en-us Tue, 29 Jul 2025 00:00:00 +0530 Thu, 01 Jan 2026 08:17:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784250 Disallowance under s.14A r.w. Rule 8D was held unsustainable because the AO failed to record the mandatory satisfaction under s.14A(2) that the assessee's claim of having incurred no expenditure to earn exempt dividend income was incorrect. The Tribunal held that the AO must examine the P&L and books to identify any expenditure relatable to exempt income and record a precise finding before invoking Rule 8D; a generalized assertion without evidentiary support does not meet the statutory threshold. Relying on SC (Maxopp), recording satisfaction was treated as a sine qua non. Consequently, the s.14A disallowance, as affirmed by CIT(A), was deleted and relief granted to the assessee. Case-Laws Income Tax Tue, 29 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784250